EXHIBIT 8
[Pages:37]EXHIBIT 8
Confidential - Subject to Protective Order
1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
2
3 THE CENTER FOR
)
DEFENSIVE DRIVING,
) IN RE:
4
)
Plaintiff,
) MYFORD TOUCH
5
) CONSUMER LITIGATION
vs.
)
6
) Case No.
FORD MOTOR COMPANY, ) 3:13-cv-03072-EMC
7
)
Defendant.
)
8
9
WEDNESDAY, OCTOBER 14, 2015
10
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER
11
? ? ?
12
Videotaped deposition of Michael
13 R. Westra, held at the offices of DYKEMA
14 GOSSETT, PLLC, 400 Renaissance Center,
15 Detroit, Michigan, commencing at 9:11 a.m.,
16 on the above date, before Carrie A. Campbell,
17 Registered Merit Reporter, Certified Realtime
18 Reporter, Certified Shorthand Reporter,
19 and Certified Court Reporter.
20
21
? ? ?
22
GOLKOW TECHNOLOGIES, INC.
23
877.370.3377 ph | 917.591.5672 fax
24
deps@
Golkow Technologies, Inc. - 1.877.370.DEPS
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1
A.
I've been made to understand
2 that it's related to a potential class action
3 lawsuit that is outstanding against the
4 MyFord Touch product or, as we refer to it
5 internally, SYNC Gen 2.
6
Q.
Okay. What is the SYNC Gen 2
7 system?
8
A.
SYNC Gen 2 system, so there's a
9 slight differentiation. SYNC Gen 2 primarily
10 referred to just the head unit and display,
11 which referred to -- which was the SYNC
12 system.
13
The MyFord Touch system
14 potentially also included the cluster,
15 electronic finish panel, essentially the
16 whole user experience around the SYNC
17 product.
18
Q.
What do you mean by "head
19 unit"?
20
A.
The head unit also is referred
21 to as infotainment system. It would be the
22 silver box that a consumer would see in the
23 dashboard, or on benches would be a silver
24 box that is attached to the display.
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1
Q.
How would you contrast the
2 SYNC 2 system with the MyFord Touch
3 experience if you were trying to explain it
4 to a family member, for example?
5
A.
So we -- the engineering sort
6 of terms would quickly get into the sort of
7 the marketing sort of side of the discussion.
8
The difference would be SYNC
9 Gen 2 would primarily be the 8-inch or, in
10 some instances, 6-inch touchscreen.
11
The MyFord Touch experience,
12 depending on what model of vehicle the
13 consumer purchased, could include, like on
14 the Lincoln, the electronic finish panel
15 slide controls which would be the -- the
16 controls that are in the -- sort of the
17 center part of the console underneath the
18 touchscreen. It would also include the
19 either single or dual LCD display in the
20 cluster.
21
So from a marketing standpoint,
22 that's sort of MyFord Touch in the larger
23 context.
24
From an engineering standpoint,
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1 primarily the focus was on SYNC 2, depending
2 on which teams were involved.
3
Q.
Okay. So today, for purposes
4 of today, since I'm not an engineer, when I
5 use the term "MyFord Touch" or "MFT" or
6 "MyLincoln Touch" or "MLT," I'm referring to
7 both the SYNC Gen 2 touchscreen as well as
8 the MyFord Touch experience as one system.
9
Can we agree that that's the
10 definition today for MyFord Touch?
11
A.
We can agree that that's the
12 definition except where clarification is
13 needed to sort of hone in on a particular
14 component.
15
Q.
Absolutely.
16
But moving forward, that's the
17 definition for today.
18
A.
Okay.
19
Q.
So more of the marketing
20 deposition -- or definition, I'm sorry.
21
A.
Yeah.
22
Q.
Excellent.
23
What are the different
24 generations of the -- just going back to the
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1
Q.
Okay. Perfect. I just want to
2 make sure we're all on the same page here.
3
So just so the record's clear,
4 when we use the words "bugs," we're referring
5 to something wrong in the MFT system that's
6 either hardware or software-related that's
7 preventing the system from performing a task
8 that it's been asked to do.
9
Does that make sense?
10
A.
It would certainly cover that.
11
In the sort of the logical
12 definition, it would also extend down to
13 misspellings that would be visible to things
14 that wouldn't necessarily even be visible
15 to -- directly to sort of -- to the consumer
16 but were internal sort of bugs that we're
17 discovering in the system.
18
Q.
Okay. I think we're on the
19 same page then.
20
A.
Okay.
21
Q.
Perfect. Thank you very much.
22
Is the MyLincoln Touch the same
23 as the MyFord Touch?
24
A.
From the standpoint of the
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1 infotainment or SYNC Gen 2 system, it is.
2
From the larger context of
3 MyFord, MyLincoln Touch, many of the
4 componentry that makes up the sort of
5 composite system would be different.
6
Q.
Can you tell me a little bit
7 more about that?
8
A.
So in terms of SYNC Gen 2, it
9 operates over the vehicle network
10 communicating to the electronic finish panel,
11 of which every -- difference that you would
12 see in the actual vehicle. So there's
13 different ones for different models of
14 Lincoln, for Explorer, Mustang, different
15 passenger vehicles on the Ford side.
16
Operates with the cluster, and
17 in some instances it's a single screen, in
18 some instances it's a dual screen. And even
19 in some instances, different suppliers have
20 provided that even if the gauges look
21 similar, and -- those would operate over the
22 vehicle network to communicate with the SYNC
23 Gen 2 central system.
24
Q.
What kind of differences would
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1 and then the color -- the color pallet would
2 be slightly different between sort of Lincoln
3 and Ford.
4
And then what you'd also
5 typically see is that the Lincolns would have
6 features that the Fords may not have. So
7 typically things like adaptive cruise
8 control, which didn't interface with SYNC at
9 all, but that would be sort of a feature that
10 initially appeared first on Lincolns and then
11 later on sort of Ford vehicles.
12
Similarly for a lot of the
13 parking features and the great -- and like
14 the cooled steering wheels initially were
15 only on Lincoln. Now, they have it on a
16 number of Fords today.
17
Q.
Anything else?
18
A.
Between those three components,
19 SYNC would interact with sort of different
20 variants of all of those, and those were sort
21 of the primary differences.
22
The base software would have
23 been the same except the Lincoln would
24 typically have different and more features
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